{"operation":"document","citation":"CPF 52023056WL","title":"MARATHON PIPE LINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-10-26","effective_on":null,"summary":"CLOSED warning letter citing 195.452(g)(1)(viii), 195.591.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023056wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023056wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023056wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52023056WL","body":"Warning Letter involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(g)(1)(viii),  195.591. The case was opened on 2023-10-26 and is reported as closed as of 2023-10-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52023056WL_Operator Response to Notice_11162023_(23-264265).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023056WL/52023056WL_Operator%20Response%20to%20Notice_11162023_(23-264265).pdf\n\n52023056WL_Warning Letter_10262023_(23-264265).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023056WL/52023056WL_Warning%20Letter_10262023_(23-264265).pdf\n\n52023056WL_Warning Letter_10262023_(23-264265)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023056WL/52023056WL_Warning%20Letter_10262023_(23-264265)_text.pdf\n\n52023056WL_Warning Letter_10262023_(23-264265)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: rjstamour@marathonpetroleum.com\nOctober 26, 2023\nMr. Rich St. Amour\nPresident\nMarathon Pipe Line LLC\n539 South Main Street\nFindlay, OH 45840\nCPF 5-2023-056-WL\nDear Mr. St. Amour:\nFrom May 31 through June 23, 2023, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Marathon Pipeline LLC’s (Marathon) crude oil and refined products pipelines in\nNikiski and Anchorage, Alaska.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 195.452 Pipeline integrity management in high consequence areas.\n(a) . . .\n(g) What is an information analysis? In periodically evaluating the integrity of each\npipeline segment (see paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of its entire pipeline and the consequences\nof a possible failure along the pipeline. Operators must continue to comply with the\ndata integration elements specified in § 195.452(g) that were in effect on October 1,\n\n\n\n2018, until October 1, 2022. Operators must begin to integrate all the data elements\nspecified in this section starting October 1, 2020, with all attributes integrated by\nOctober 1, 2022. This analysis must:\n(1) Integrate information and attributes about the pipeline that include, but are not\nlimited to:\n(i) . . .\n(viii) Data gathered through integrity assessments required under this section;\nMarathon failed to integrate and analyze data gathered through their 2021 integrity assessments\nfor their Kenai Refinery to Anchorage refined products pipeline, as required. Specifically, in\n2021, Marathon conducted an integrity assessment using a suite of in-line inspection (ILI) tools\n(including a UT crack tool, a circumferential UT crack tool, a geometry (caliper) tool, a\ncorrosion assessment tool (MFL), and an inertial mapping tool). These integrity assessments\nwere completed between February and April 2021. During PHMSA’s 2023 inspection, Marathon\nstated that it integrates and analyzes ILI assessment data through the process of preparing a Data\nIntegration Report. However, Marathon could not produce any records demonstrating it had\ncompleted the Date Integration Report nor any other record of ILI data integration for their 2021\nassessments as of the May 2023 inspection.\nTherefore, Marathon failed to comply with § 195.452(g)(1)(viii) by not integrating and analyzing\nits ILI data as required.\n2. § 195.591 In-Line inspection of pipelines.\nWhen conducting in-line inspection of pipelines required by this part, each operator\nmust comply with the requirements and recommendations of API Std 1163, Inline\nInspection Systems Qualification Standard; ANSI/ASNT ILI–PQ, Inline Inspection\nPersonnel Qualification and Certification; and NACE SP0102–2010, Inline Inspection\nof Pipelines (incorporated by reference, see § 195.3). An in-line inspection may also\nbe conducted using tethered or remote control tools provided they generally comply\nwith those sections of NACE SP0102–2010 that are applicable.\nMarathon failed to comply with API Std 1163 as required. Specifically, during inspection,\nMarathon had not validated the results of their 2021 in-line inspections (ILI) of their Kenai\nRefinery to Anchorage refined products pipeline. ILI data validation is a process required by API\nStd 1163. Between February and April 2021, Marathon conducted an integrity assessment using\na suite of ILI tools (including a UT crack tool, a circumferential UT crack tool, a geometry\n(caliper) tool, a corrosion assessment tool (MFL), and an inertial mapping tool). During the\n2023 inspection, Marathon stated that its ILI validation process is completed and documented\nthrough the process of preparing a Data Integration Report. However, Marathon could not\nprovide the completed Data Integration Report nor any other record of ILI validation for its 2021\nassessments as of the May 2023 inspection.\nTherefore, Marathon failed to comply with § 195.591 by not validating the results of its 2021 ILI\nassessments as required per API Std 1163.\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a\nrelated series of violations. For violation occurring on or after March 21, 2022, and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021, and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021, and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019, and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations. For violation occurring on or after November 27, 2018, and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015, and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nMarathon Pipe Line LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply in your correspondence, please refer to\nCPF 5-2023-056-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document, you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nCC:\nPHP-60 Compliance Registry\nPHP-500 J. Gano (#23-264265)","truncated":false,"body_characters":7971}